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HOSPITAL CORP. OF AMERICA SUBSIDIARIES v. C.I.R.

No. 01-1810.

348 F.3d 136 (2003)

HOSPITAL CORPORATION OF AMERICA & SUBSIDIARIES, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided and Filed: October 30, 2003.

Petition for Rehearing Denied: February 17, 2004.

Attorney(s) appearing for the Case

ARGUED: N. Jerold Cohen (argued and briefed), Walter H. Wingfield (briefed), Teresa W. Roseborough (briefed), Amanda B. Scott (briefed), Thomas A. Cullinan (briefed), Matthew J. Gries (briefed), SUTHERLAND, ASBILL & BRENNAN, Atlanta, Georgia, for Appellant.

Teresa E. McLaughlin (briefed), Thomas J. Sawyer (argued and briefed), UNITED STATES DEPARTMENT OF JUSTICE, APPELLATE SECTION TAX DIVISION, Washington, D.C., for Appellee.

ON BRIEF: N. Jerolf Cohen, Walter H. Wingfield, Teresa W. Roseborough, Amanda B. Scott, Thomas A. Cullinan, Matthew J. Gries, SUTHERLAND, ASBILL & BRENNAN, Atlanta, Georgia, for Appellant.

Thomas J. Sawyer, Teresa E. McLaughlin, UNITED STATES DEPARTMENT OF JUSTICE, APPELLATE SECTION TAX DIVISION, Washington, D.C., for Appellee.

Before: MARTIN and ROGERS, Circuit Judges; EDMUNDS, District Judge.

Petition for Rehearing Denied En Banc: February 17, 2004.

Pursuant to Sixth Circuit Rule 206

OPINION

BOYCE F. MARTIN, JR., Circuit Judge.

The petitioner, Hospital Corporation of America and subsidiaries, appeals from two decisions of the United States Tax Court ruling in favor of the Commissioner of the Internal Revenue. First, the Tax Court found that the Secretary of the Treasury reasonably interpreted...

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